AMEENAMMA CHARITBLE TRUST,ANANTAPUR vs. ITO, (EXEMPTION) WARD-TIRUPATI, TIRUPATI

In the result, appeal filed by the assessee Trust is partly allowed in terms of our aforesaid observations

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.1841/Hyd/2025 (िनधा"रण वष"/Assessment Year:2016-17) Ameenamma Charitable Vs. Income Tax Officer Trust, (Exemption) Ward – Anantapur. Tirupati. Pan: Aaeta7403P (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Ka Sai Prasad, Ca राज" व "ारा/Revenue By: Shri K Vamsi Krishna, Sr.Ar सुनवाई की तारीख/Date Of Hearing: 04/02/2026 घोषणा की तारीख/Date Of 20/02/2026 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Present Appeal Filed By The Assessee Trust Is Directed Against The Order Passed By The Additional/Joint Commissioner Of Income Tax (Appeals)-1, Chennai, Dated 03/10/2025, Which In Turn Arises From The Order Passed By The Income Tax Officer, Exemption Ward, Tirupati (For Short, “Ao”) Under Section 143(3) Of The Income Tax Act, 1961 (For Short, “The Act”), Dated 14/12/2018 For The Assessment Year (Ay) 2016-17. The Assessee Has Assailed The Impugned Order Of The Cit(A) On The Following Grounds Of Appeal:

Charitable Trust vs. ITO not apply to the income referred as anonymous donations, as discussed in point (2) of the assessment order. 4. Apart from that, the AO observed that the gross income of the assessee Trust during the subject year amounted to Rs.11,78,000/-. As the assessee Trust is stated to have failed to file the complete details

ACIT, CENTRAL CIRCLE-3(1), HYDERABAD vs. SRI CHAITANYA EDUCATIONAL COMMITTE, VIJAYAWADA

In the result, the appeal filed by the Revenue is dismissed

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

charitable society enjoying the benefit of Sec. 12 has no relevancy to determine whether the income of the society was used for the benefit of the specified persons u/s. 13(3) of the IT Act, in violation of the provisions of Sec. 13(1)(c), 13(2)(c) and 13(2)(g) of the IT Act. 5. In the facts

MYADAM KISHAN RAO CHARITABLE TRUST,HYDERABAD vs. COMMISSIONER OF INCOME TAX (EXEMPTIONS), HYDERABAD

In the result, the appeal of the assessee is allowed

Bench: Shri Manjunatha G., Hon'Ble & Shri K.Narasimha Chary, Hon'Ble

charitable or Page 14 of 27 religious purposes has been applied other than for the objects of the Trust and (b) the Trust or institution has income from profits and gains of business, which is not incidental to the attainment of its objects and the trust not maintains separate books of accounts (c) Trust or institution is applied its income

ACIT,CIRCLE-13(1), HYDERABAD vs. M/S SURESH PRODUCTIONS PVT. LTD.,, HYDERABAD

Accordingly, the ground of the revenue is allowed

Bench: Shri K. Narasimha Chary & Shri Madhusudan Sawdia

24,455/-, disallowing deduction of Rs.13,49,408/- u/s. 80IA of the Act and making additions Rs.11,82,480/- u/s.40(a)(ia) of the Act & Rs.2,25,00,000/- u/s. 40A(2)(b) of the Act. ITA NO.1633/HYD/2014 : 6. The Revenue has raised as many as 5 grounds in this appeal. The Ground Nos. 1 and 5 are general

ACIT., EXEMPTIONS CIRCLE-1(1), HYDERABAD vs. PHARMACEUTICALS EXPORT PROMOTION COUNCIL OF INDIA, HYDERABAD

In the result, the appeal of Revenue is allowed

Bench: Shri Laliet Kumar, Hon’Ble & Shri G. Manjunatha, Hon’Bleassessment Year: 2016-17 The Assistant Commissioner Vs. Pharmaceuticals Export Of Income Tax, Promotion Council Of India, Exemptions, Circle – 1(1), Hyderabad. Hyderabad. Pan : Aadcp4643C (Appellant) (Respondent) Assessee By: Shri Rv. Chalam, C.A. Revenue By: Shri B. Balakrishna, Cit-Dr Date Of Hearing: 10.02.2025 Date Of Pronouncement: 11.02.2025

charitable or religious purposes outside India. It was further held that the words "in India" appearing in section ll(l)(a) and the words "outside India" appearing in section 11(l)(c) qualified the word "applied" appearing in these provisions and not the words "said purposes." 8. Thus, it is well settled law that the expenditure incurred by the trust

SRI VENKATESWARA SWAMY DEVASTANAM,JAMALAPURAM vs. ITO., EXEMPTION WARD-1(3), HYDERABAD

In the result, both the appeals filed by the assessee are partly allowed

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha, G.आ.अपी.सं /Ita Nos.1002 & 1003/Hyd/2024 (िनधा"रण वष"/Assessment Years: 2013-14 & 2016-17) Sri Venkateswara Swamy Vs. Income Tax Officer Devasthanam (Exemption), Ward 1(3) Jamalapuram Hyderabad Pan:Aamts2301Q (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Advocate E Hari Babu राज" व "ारा/Revenue By:: Dr. Sachin Kumar, Dr सुनवाई की तारीख/Date Of Hearing: 14/05/2025 घोषणा की तारीख/Pronouncement: 03/07/2025 आदेश/Order Per Vijay Pal Raothese Appeals Filed By The Assessee Are Directed Against Two Separate Orders, Both Dated 19/02/2024 Of The Learned Cit (A)-Nfac Delhi, For The A.Ys. 2013-14 & 2016-17. 2. There Is A Delay Of 160 Days In Filing The Present Appeals. The Assessee Has Filed An Application For Condonation Of Delay. The Learned Ar Of The Assessee Has Submitted That During The Pendency Of The Appeal Before The Learned Cit (A), The Assessee Filed A Writ Petition Before The Hon'Ble High Court For Issuing Directions To The Learned Cit (A) & The Hon'Ble High Court Was Pleased To Give Directions To The Learned Cit (A)

2 appeals except the quantum of addition. The grounds raised by the assessee for the ay 2013-14 are reproduced as under: Page 3 of 37 ITA Nos 1002 and 1003 of 2024 Sri Venkateswara Swamy Devastanam Page 4 of 37 ITA Nos 1002 and 1003 of 2024 Sri Venkateswara Swamy Devastanam Page

SRI VENAKTESWARA SWAMY DEVASTANAM,,JAMALAPURAM vs. ITO., EXEMPTION WARD1- (3), HYDERABAD

In the result, both the appeals filed by the assessee are partly allowed

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha, G.आ.अपी.सं /Ita Nos.1002 & 1003/Hyd/2024 (िनधा"रण वष"/Assessment Years: 2013-14 & 2016-17) Sri Venkateswara Swamy Vs. Income Tax Officer Devasthanam (Exemption), Ward 1(3) Jamalapuram Hyderabad Pan:Aamts2301Q (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Advocate E Hari Babu राज" व "ारा/Revenue By:: Dr. Sachin Kumar, Dr सुनवाई की तारीख/Date Of Hearing: 14/05/2025 घोषणा की तारीख/Pronouncement: 03/07/2025 आदेश/Order Per Vijay Pal Raothese Appeals Filed By The Assessee Are Directed Against Two Separate Orders, Both Dated 19/02/2024 Of The Learned Cit (A)-Nfac Delhi, For The A.Ys. 2013-14 & 2016-17. 2. There Is A Delay Of 160 Days In Filing The Present Appeals. The Assessee Has Filed An Application For Condonation Of Delay. The Learned Ar Of The Assessee Has Submitted That During The Pendency Of The Appeal Before The Learned Cit (A), The Assessee Filed A Writ Petition Before The Hon'Ble High Court For Issuing Directions To The Learned Cit (A) & The Hon'Ble High Court Was Pleased To Give Directions To The Learned Cit (A)

2 appeals except the quantum of addition. The grounds raised by the assessee for the ay 2013-14 are reproduced as under: Page 3 of 37 ITA Nos 1002 and 1003 of 2024 Sri Venkateswara Swamy Devastanam Page 4 of 37 ITA Nos 1002 and 1003 of 2024 Sri Venkateswara Swamy Devastanam Page

CMR EDUCATIONAL SOCIETY,HYDERABAD vs. DCIT., CENTRAL CIRCLE-2(1), HYDERABAD

In the result, the appeal filed by the assessee in ITA

Bench: SHRI VIJAY PAL RAO, HON’BLE (Vice President), SHRI MANJUNATHA G, HON’BLE (Accountant Member)

2) All applications, pending before the Principal Commissioner or Commissioner on which no order has been passed under clause (b) of sub-section (1) of section 12AA before the date on which this section has come into force, shall be deemed to be an application made under sub- clause (vi) of clause (ac) of sub-section (1) of section

CMR EDUCATIONAL SOCIETY,HYDERABAD vs. DCIT., CENTRAL CIRCLE-2(1), HYDERABAD

In the result, the appeal filed by the assessee in ITA

Bench: SHRI VIJAY PAL RAO, HON’BLE (Vice President), SHRI MANJUNATHA G, HON’BLE (Accountant Member)

2) All applications, pending before the Principal Commissioner or Commissioner on which no order has been passed under clause (b) of sub-section (1) of section 12AA before the date on which this section has come into force, shall be deemed to be an application made under sub- clause (vi) of clause (ac) of sub-section (1) of section

MALLA REDDY EDUCATIONAL SOCIETY,HYDERABAD vs. DCIT., CENTRAL CIRCLE-2(1), HYDERABAD

In the result, the appeal filed by the assessee in ITA

Bench: SHRI VIJAY PAL RAO, HON’BLE (Vice President), SHRI MANJUNATHA G, HON’BLE (Accountant Member)

2) All applications, pending before the Principal Commissioner or Commissioner on which no order has been passed under clause (b) of sub-section (1) of section 12AA before the date on which this section has come into force, shall be deemed to be an application made under sub- clause (vi) of clause (ac) of sub-section (1) of section

MALLA REDDY EDUCATIONAL SOCIETY,HYDERABAD vs. DCIT., CENTRAL CIRCLE-2(1), HYDERABAD

In the result, the appeal filed by the assessee in ITA

2) All applications, pending before the Principal Commissioner or Commissioner on which no order has been passed under clause (b) of sub-section (1) of section 12AA before the date on which this section has come into force, shall be deemed to be an application made under sub- clause (vi) of clause (ac) of sub-section (1) of section

K M R EDUCATIONAL SOCIETY,HYDERABAD vs. DCIT., CENTRAL CIRCLE-2(1), HYDERABAD

In the result, the appeal filed by the assessee in ITA

Bench: SHRI VIJAY PAL RAO, HON’BLE (Vice President), SHRI MANJUNATHA G, HON’BLE (Accountant Member)

2) All applications, pending before the Principal Commissioner or Commissioner on which no order has been passed under clause (b) of sub-section (1) of section 12AA before the date on which this section has come into force, shall be deemed to be an application made under sub- clause (vi) of clause (ac) of sub-section (1) of section

K M R EDUCATIONAL SOCIETY,HYDERABAD vs. DCIT., CENTRAL CIRCLE-2(1), HYDERABAD

In the result, the appeal filed by the assessee in ITA

Bench: SHRI VIJAY PAL RAO, HON’BLE (Vice President), SHRI MANJUNATHA G, HON’BLE (Accountant Member)

2) All applications, pending before the Principal Commissioner or Commissioner on which no order has been passed under clause (b) of sub-section (1) of section 12AA before the date on which this section has come into force, shall be deemed to be an application made under sub- clause (vi) of clause (ac) of sub-section (1) of section

MARUTHI EDUCATIONAL SOCIETY,HYDERABAD vs. DCIT., CENTRAL CIRCLE-2(1), HYDERABAD

In the result, the appeal filed by the assessee in ITA

Bench: SHRI VIJAY PAL RAO, HON’BLE (Vice President), SHRI MANJUNATHA G, HON’BLE (Accountant Member)

2) All applications, pending before the Principal Commissioner or Commissioner on which no order has been passed under clause (b) of sub-section (1) of section 12AA before the date on which this section has come into force, shall be deemed to be an application made under sub- clause (vi) of clause (ac) of sub-section (1) of section

CMR ENGINEERING EDUCATIONAL SOCIETY,HYDERABAD vs. DCIT., CENTRAL CIRCLE-2(1), HYDERABAD

In the result, the appeal filed by the assessee is allowed

Bench: SHRI VIJAY PAL RAO, HON’BLE (Vice President), SHRI MANJUNATHA G, HON’BLE (Accountant Member)

2) All applications, pending before the Principal Commissioner or Commissioner on which no order has been passed under clause (b) of sub-section (1) of section 12AA before the date on which this section has come into force, shall be deemed to be an application made under sub- clause (vi) of clause (ac) of sub-section (1) of section

NETENRICH TECHNOLOGIES PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE - 5(1), HYDERABAD

In the result, the appeal filed by the assessee is allowed

Bench: SHRI MANJUNATHA G. (Accountant Member), SHRI K.NARASIMHA CHARY (Judicial Member)

2) All applications, pending before the Principal Commissioner or Commissioner on which no order has been passed under clause (b) of sub-section (1) of section 12AA before the date on which this section has come into force, shall be deemed to be an application made under sub- clause (vi) of clause (ac) of sub-section (1) of section

MARRI EDUCATIONAL SOCIETY,HYDERABAD vs. DCIT., CENTRAL CIRCLE-2(1), HYDERABAD

In the result, the appeal filed by the assessee in ITA

Bench: SHRI VIJAY PAL RAO, HON’BLE (Vice President), SHRI MANJUNATHA G, HON’BLE (Accountant Member)

2) All applications, pending before the Principal Commissioner or Commissioner on which no order has been passed under clause (b) of sub-section (1) of section 12AA before the date on which this section has come into force, shall be deemed to be an application made under sub- clause (vi) of clause (ac) of sub-section (1) of section

CMR TECHNICAL EDUCATION SOCIETY,HYDERABAD vs. DCIT., CENTRAL CIRCLE-2(1), HYDERABAD

In the result, the appeal filed by the assessee in ITA

Bench: SHRI VIJAY PAL RAO, HON’BLE (Vice President), SHRI MANJUNATHA G, HON’BLE (Accountant Member)

2) All applications, pending before the Principal Commissioner or Commissioner on which no order has been passed under clause (b) of sub-section (1) of section 12AA before the date on which this section has come into force, shall be deemed to be an application made under sub- clause (vi) of clause (ac) of sub-section (1) of section

CMR TECHNICAL EDUCATION SOCIETY,HYDERABAD vs. DCIT., CENTRAL CIRCLE-2(1), HYDERABAD

In the result, the appeal filed by the assessee in ITA

2) All applications, pending before the Principal Commissioner or Commissioner on which no order has been passed under clause (b) of sub-section (1) of section 12AA before the date on which this section has come into force, shall be deemed to be an application made under sub- clause (vi) of clause (ac) of sub-section (1) of section